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records, and the investigation essentially focused on attempting
to re-create the financial transactions of the corporation. Ms.
Taylor, who primarily maintained the financial records, did not
cooperate with the investigation, and petitioner's cooperation
was limited. The investigators had to issue summonses to third
parties to obtain records.
When CID accepts a case, the special agent of CID and the
revenue agent of the Internal Revenue Service (Examination
Division) may undertake a joint investigation; the special agent,
however, controls the investigation. Normally the revenue agent
continues to investigate the civil aspects, but the revenue agent
would have no contact with the taxpayer unless the special agent
was present. The special agent is interested in obtaining
evidence of violations of criminal statutes. See United States
v. Crespo, 281 F. Supp. 928, 931-932 (D. Md. 1968). On August
19, 1991, the Examination Division placed its examination of
petitioner's liability in the "Fraud Suspense" category. At that
time the revenue agent prepared a preliminary computation with
the understanding that the civil aspects of the case would remain
in suspense until the criminal aspects were completed. While the
case was in "Fraud Suspense", it was decided by the District
Director that the normal period of limitations for the 1984,
1985, 1986, and 1987 tax years would be allowed to expire without
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